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Emergi Mentors Privacy Policy: Your Data, Our Commitment

At Emergi Mentors Pty Ltd (“Emergi Mentors”, “we”, “our” or “us”), we are committed to protecting your privacy and ensuring that your personal data is handled securely and responsibly. This Group Privacy Policy (Privacy Policy) outlines how we collect, use, store, and disclose your personal data. This Privacy Policy complies with the Eurpoean General Data Protection Regulation (GDPR), the UK Data Protection Act 1998 (DPA), the Australian Privacy Act (Privacy Act), the Singaporean Personal Data Protection Act (PDPA), the California Consumer Privacy Act (CCPA), and other applicable privacy laws and regulations. By using our website (Home), platform and services, you agree to the terms of this Privacy Policy. This Privacy Policy is effective as at 5th July 2024.

What is Personal Data?

Personal data means information about an identified or identifiable natual person who can be identified, directly or indirectly with reference to an identifier. Identifiers may include your name, identification number, location data, an online identifier, address, email, phone and other items prescribed under either the GDPR, DPA, Privacy Act, PDPA or CCPA.

Information We Collect

When you use our website and services, we collect the following types of information :

(a)

Personal data: This includes your name, residential address, email address, phone, payment information, and any other information you provide when you create an account, utilise any of our services, subscribe to our newsletter, or contact us.

(b)

Historical Data: We collect data related to your account activities and preferences, such as your usage of the Emergi Mentors website, mobile applications, platform, and transaction history.

(c)

Usage Information: We collect data about your interactions with our website, mobile applications, and platforms, including pages visited, time spent on the site or mobile app page, and other behavioral information.

(d)

Device and Technical Information: We collect information about your device, browser, operating system, and IP address.

Implied Consent and Withdrawal of Consent

By accessing our website, mobile applications or platforms, or utilising our services you consent to us collecting, using or disclosing your information including any personal data (as prescribed in clause 3 of this Privacy Policy). We assume your consent to continue to use, store and, where applicable, disclose your personal data that we have already collected, for the purpose for which the information was collected.

You acknowledge and agree that without your consent to provide your personal data we may not be able to provide access to certain features on our website, platforms or mobile applications, as well as provide our services to you, in whole or in part. If we rely on your consent to process your personal data, you have the right to withdraw consent at any time by contacting us at [email protected]

Consent to Marketing Communications

4.1 Express Consent Required

We will only send you marketing communications (including promotional emails, SMS messages, push notifications, or other electronic messages) where you have provided clear and express consent in accordance with the Spam Act 2003 (Cth), the Privacy Act 1988 (Cth), and other applicable privacy laws.

4.2 How We Obtain Consent

You may provide consent through any of the following methods:

(a) Actively selecting an opt-in checkbox on our website, forms, or mobile application.

(b) Subscribing to our newsletter, updates, or marketing lists.

(d) Providing written consent via email or documented verbal consent.

(e) Engaging with us in a way that reasonably indicates consent to receive marketing communications

4.3 Consent Records

We maintain comprehensive records of all marketing consents, including:

(a) Date and time consent was obtained

(b) Method of consent (e.g., web form, email, verbal)

(d) Specific types of communications consented to

(e) IP address and other relevant technical data where applicable

4.4 Withdrawing Consent

You have the right to withdraw your consent at any time, free of charge. You can do this by:

(a) Clicking the unsubscribe link in any marketing email

(b) Replying STOP to any SMS marketing message

(d) Emailing us at [email protected]

(e) Calling us on +61 426 135 357

4.5 Transactional Communications

This consent requirement does not apply to transactional or service-related communications necessary for the operation of your account or the delivery of our services.

Platform Messaging and Notifications

5.1 Messaging System

Our platform facilitates direct communication between mentors and mentees through a secure, built-in messaging system designed to enhance the mentoring experience.

5.2 Automated Notifications

To ensure timely communication and improve user engagement:

(a) We send automated email notifications when you receive a new message.

(b) Notifications are generated automatically based on messaging events

5.3 Privacy of Message Content

We respect the privacy of your communications:

(a) Message content is not read, reviewed, or analysed by our staff for notification purposes

(b) Notifications are triggered automatically by system events

5.4 Data Processing

For the messaging notification system, we process only:

(a) Sender and recipient identifiers

(b) Timestamp of messages

(e) Notification delivery status

We do not store, analyse, or access the actual content of messages for notification purposes.

5.5 Managing Notifications

You can control messaging notifications by:

(a) Adjusting notification preferences in your account settings

(b) Selecting specific notification types you wish to receive

(e) Disabling notifications entirely while maintaining messaging functionality

(e) Contacting us at [email protected] for assistance

5.6 Message Retention

Messages within our platform are retained for the duration of the active mentor-mentee relationship plus 12 months, unless earlier deletion is requested by either party.

Sources of Personal Data

You acknowledge and agree that if we do not collect personal data directly from you, we may obtain it from third-party sources including but not limited to through social media platforms or marketing partners.

How We Use Your Information

We use your information to:

(a) Provide, operate, maintain, and improve our services;

(b) Personalise your experience, including offering customised machine learning enhancements and recommendations;

(d) Communicate with you about our services, promotions, and updates;

(e) Analyse and monitor user activity to optimise our website, mobile applications, platforms and services;

(f) Conduct such marketing activites as determined by us in our absolute discretion;

(g) Detect and prevent fraud, abuse, technical issues and security incidents; and

(h) Comply with legal obligations and enforce any and all of our terms of service or legal rights.

Sharing Your Information

We do not sell, monotise, profile or make automated decisions with respect to your personal data under any circumstances whatsoever. We may share your information with third parties in the following circumstances:

(a)

Service Providers: We may share your information with third-party service providers who perform functions on our behalf, such as payment processing, analytics, and marketing services.

(b)

Affiliates: We may share your information with our affiliates, in which case we shall require them to comply with the requirements of this Privacy Policy.

(c)

Compliance with Legal Requirements: We may disclose your information if required by law or in response to legal processes, such as a court order or a subpoena.

(d)

Research and Development: We may share anonymised data with research partners for the purpose of improving our services and developing new features.

(e)

M&A Activity: In connection with mergers, sales, or acquisitions of our company.

International Transfers

Your personal data may be transferred to countries outside the European Union, UK, Australia, Singapore and the United States. We ensure adequate protection is provided through standard contractual clauses and other appropriate measures.

10.

Cookies and Tracking Technologies

We use cookies and other tracking technologies to improve your experience on our website. Cookies help us remember your preferences, analyse site usage, and tailor content and advertisements. You can manage your cookie preferences through your browser settings. Please refer to our Cookie Policy for further information.

11.

Data Security and Reliance

We implement appropriate security measures, depending on the sensitivity of the information, to protect your personal data from unauthorised access, alteration, use, destruction or disclosure.

Please be aware that we are not responsible for the privacy practices of other websites that we link to. We encourage you to read the privacy statements of each and every website that requests personal data from you.

We rely on you to notify us if there is a change to your personal data that may affect your relation with us. If you are aware of an error in our information about you, please contact us as soon as possible. Please be advised that, in some instances, we may ask for a written request for correction.

If you have provided personal data to us, from time to time, we may contact you to conduct surveys and seek feedback from you to inprove our level of service which may include our data security practices. Please note that de-identified data concerning the findings of such surveys may be published, however we shall not share individual data.

12.

Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which is was collected and to comply with any legal obligations. When your data is no longer needed, we shall securly delete or anonymise it.

13.

Children’s Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children under 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete such information.

14.

Your Rights

You have the following rights regarding your personal data:

(a)

Right to Know: You have the right to know what personal data is being collected and how it is used.

(b)

Right to Access: Request access to your personal data.

(c)

Right to Rectification: Request correction of inaccurate or incomplete data.

(d)

Right to Erasure: Request deletion of your personal data.

(e)

Right to Restrict Processing: Request restriction of processing your personal data.

(f)

Right to Data Portability: Request transfer of your personal information to you or a third party.

(g)

Right to Object: Object to the processing of your personal data.

(h)

Rights related to Automated Decision-making: Not to be subject to decisions based solely on automated processing.

(i)

Right to Withdraw Consent: You have the right to withdraw your consent for the collection, use, processing or retention of your personal data at any time.

(j)

Right to Lodge a Complaint: If you have any concerns about our use of your personal data, you can lodge a complaint with the relevant supervisory authority.

(k)

Right to Non-Discrimination: You have the right to not be discriminated against for exercising your rights under either the GDPR, DPA, Privacy Act, PDPA, or CCPA.

15.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page, and accordingly, your continued use of our website and services constitutes your acceptance of the revised Privacy Policy.

16.

Identity and Contact Details of the Controller

Emergi Mentors is the data controller with reference to this Privacy Policy. Please refer to relevant details prescribed below.

Company Name: Emergi Mentors Pty Ltd

ACN / Company Registration No: 677 084 883

Registered Office Address: Unit B, 79 Great Western Highway, Oxley Park, NSW, Australia 2760

Email: [email protected]

Phone Number: +61 426 135 357

17.

Contact Details of the Data Protection Officer (DPO)

If you have any questions or concerns about this Privacy Policy or about any collection, use, storage or disclosure of personal data by us, please contact our DPO at:

DPO Name: Fassahat Ullah Qureshi

Email: [email protected]

Phone Number: +61 426 135 357

18.

Data Breach Policy

Emergi Mentors has a comprehensive policy addressing data breaches which sets out the steps we will take to contain and mitigate the breach, assess its impact, and notify affected individuals and relevant authorities as required by applicable laws and regulations (Data Breach Policy). This Data Breach Policy is contained in Annexure 1 – Data Breach Policy and forms part of this Privacy Policy.

Annexure 1 – Data Breach Policy

At Emergi Mentors Pty Ltd (“Emergi Mentors”, “we”, “our” or “us”), we are committed to protecting the personal data of its users and clients. In the event of a data breach, we will take immediate steps to contain and mitigate the breach, assess its impact, and notify affected individuals and relevant authorities as required by applicable laws and regulations. This Data Breach Policy outlines our procedures for responding to data breaches and ensuring compliance with applicable privacy laws and regulations. This Data Breach Policy is effective as at 5th July 2024.

What is a Data Breach?

A data breach is defined as a security incident that results in the unauthorised access, disclosure, alteration, loss, or destruction of personal data. Examples of data breaches include the:

(a) Unauthorised access to personal data by a third party;

(b) Accidental or unlawful destruction, loss, or alteration of personal data;

(d) Ransomware attacks.

Reporting a Data Breach – Internal Reporting

All employees, contractors, and third-party service providers of Emergi Mentors must report any suspected or actual data breach immediately to the Data Protection Officer (DPO) or the designated incident response team. Reports should include:

(a) The date and time the breach was discovered;

(b) A description of the breach;

(d) The potential impact on individuals; and

(e) Any actions taken to contain the breach.

Containment and Recovery

3.1 Immediate Actions

Upon receiving a data breach report, the DPO or incident response team will:

(a) Initiate an immediate investigation to confirm the breach;

(b) Contain the breach to prevent further data loss or unauthorised access;

(d) Assess the severity and impact of the breach.

3.2 Notification to Management

The DPO or incident response team will notify senior management of Emergi Mentors of the breach, providing details of the incident, actions taken, and potential impact.

Risk Assessment

The DPO or incident response team will conduct a risk assessment to evaluate the potential impact of the breach on affected individuals and the organisation. This assessment will consider:

(a) The nature and sensitivity of the data involved;

(b) The potential consequences for affected individuals;

(d) Any measures already in place to mitigate the impact.

Notification of Affected Individuals

5.1 Timing and Method of Notification

If the risk assessment determines that the breach is likely to result in a high risk to the rights and freedoms of affected individuals, we will notify those individuals without undue delay. Notifications will be made via email, postal mail, or other appropriate communication channels.

5.2 Content of Notification

The notification to affected individuals will include:

(a) A description of the nature of the breach;

(b) The types of personal data affected;

(d) The measures taken or proposed to be taken to address the breach; and

(e) Contact details for further information and assistance.

Notification to Regulatory Authorities

6.1 GDPR and UK DPA

Under the GDPR and UK DPA, we are required to notify the relevant supervisory authority of a data breach within 72 hours of becoming aware of it, unless the breach is unlikely to result in a risk to the rights and freedoms of individuals. The notification will include:

(a) A description of the nature of the breach;

(b) The types of personal data affected;

(d) The likely consequences of the breach; and

(e) The measures taken or proposed to be taken to address the breach.

6.2 Australian Privacy Act

Under the Australian Privacy Act, we are required to notify the Office of the Australian Information Commissioner (OAIC) if a data breach is likely to result in serious harm to affected individuals. The notification will include:

(a) A description of the nature of the breach;

(b) The types of personal data affected;

(d) Contact details for further information.

6.3 Singapore PDPA

Under the PDPA, we are required to notify the Personal Data Protection Commission (PDPC) if a data breach results in, or is likely to result in, significant harm to affected individuals or if the breach is of a significant scale. The notification will include:

(a) A description of the nature of the breach;

(b) The types of personal data affected;

(d) The steps taken to mitigate the impact of the breach.

6.4 CCPA

Under the CCPA, we are required to notify the California Attorney General if a data breach affects more than 500 California residents. The notification will include:

(a) A description of the nature of the breach;

(b) The types of personal data affected;

(d) The steps taken to mitigate the impact of the breach.

Documentation and Review

We will document all data breaches, including the details of the incident, actions taken, and notifications made. This documentation will be used to review and improve our data breach response procedures regularly.

Training and Awareness

All employees, contractors, and third-party service providers of Emergi Partners will receive regular training on data breach identification, reporting, and response procedures to ensure a timely and effective response to data breaches.

Contact Information

If you have any questions or concerns about this Data Breach Policy, please contact our DPO at:

DPO Name: Fassahat Ullah Qureshi

Email: [email protected]

Phone Number: +61 426 135 357